concurring:
While I concur in the result, I write separately because I would analyze differently the issue of whether the GPPA can supplement admiralty law. I would hold application of the GPPA would disrupt the proper harmony and uniformity of admiralty law, and thus I would not reach the issue of whether the American Rule is a characteristic feature of admiralty law.
In American Dredging, the Court found a state law rejecting forum non conveniens did not disrupt the uniformity of maritime law because the doctrine “is procedural rather than substantive, and it is most unlikely to produce uniform results.” 510 U.S. at 453, 114 S.Ct. at 988. The American Dredging Court also found forum non conveniens would not disrupt the uniformity of admiralty law because it would have little effect on parties’ conduct both inside and outside the courtroom. Id. at 454-55, 114 S.Ct. at 988-89.1
*842Unlike forum non conveniens, the American Rule is a substantive law that yields consistent and predictable results.2 Moreover, attorneys’ fees can be a substantial portion of a party’s recovery and thus could influence secondary behavior, such as a decision of where to sue. Other courts that have considered the application of state statutes providing for attorneys’ fees in maritime eases have also concluded uniformity is an important interest. See Sosebee v. Rath, 893 F.2d 54, 56-57 (3d Cir.1990); Texas A&M Research Found. v. Magna Transp., Inc., 338 F.3d 394, 406 (5th Cir.2003); Garan, Inc. v. M/V Aivik, 907 F.Supp. 397, 401 (SJD.Fla.1996). Although I concur the GPPA cannot supplement admiralty law in this case, I would conclude its application would disrupt the proper harmony and uniformity of admiralty law.
. The Court in American Dredging states the uniformity analysis is not limited to the state law's impact on maritime commerce. Id. at 453 n. 3, 114 S.Ct. at 988 n. 3. As the Court indicates, however, the Supreme Court’s uni*842formity analysis has not been entirely clear or consistent. See id. at 452, 114 S.Ct. at 987.
. Norfolk argues the exceptions to the American Rule demonstrate that maritime law already tolerates a lack of uniformity in the provision of attorneys' fees. These exceptions, however, are consistently applied on a national level. The American Rule thus yields consistent and predictable results despite its limited exceptions.